News & Analysis as of

Internal Revenue Service HIRE Act

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Allen Barron, Inc.

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on

Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more

Orrick - On the Chain

IRS Hints at Form 8938 Requirements for Reporting Crypto Assets Held at a Foreign Exchange

Orrick - On the Chain on

With the emergence of digital assets, the question has arisen whether digital assets held in “wallets” in foreign exchanges need to be reported on Internal Revenue Service (IRS) Form 8938, Statement of Specified Foreign...more

Dechert LLP

IRS Issues Proposed FATCA Regulations

Dechert LLP on

On December 13, 2018, U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) that would amend the current regulations relating to the Foreign Account Tax...more

Dechert LLP

Much-Anticipated Section 871(m) Dividend Equivalent Guidance Provides Promised Transition Relief

Dechert LLP on

The U.S. Internal Revenue Service (the “IRS”) has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend equivalent transactions described in section 871(m) of the U.S. Internal...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Financial Institutions Wrestle With FATCA Implementation"

Over the past year, financial institutions have wrestled with the challenges presented by the U.S. Foreign Tax Compliance Act (FATCA). Originally scheduled to take effect in 2013, the U.S. Treasury Department and IRS have...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Treasury and IRS Move to Implement FATCA as 2014 Start Date Approaches"

On October 29, 2013, the IRS issued Notice 2013-69 as the next step in implementing far-reaching legislation commonly known as the Foreign Account Tax Compliance Act (FATCA). Congress enacted FATCA in 2010 as part of...more

Orrick, Herrington & Sutcliffe LLP

Final Regulations Implementing the Foreign Account Tax Compliance Act (“FATCA”)

On January 17, 2013, the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) implementing the reporting and withholding provisions of the HIRE Act (commonly known as the Foreign Account Tax...more

Butler Snow LLP

FATCA: Final Regulations Raise Questions for Trust Practitioners

Butler Snow LLP on

In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more

Morrison & Foerster LLP

After Months of Anticipation, Final FATCA Regulations Released

BACKGROUND - On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations implementing the Foreign Account Tax Compliance Act (“FATCA”). ...more

Akerman LLP

IRS Releases Draft Form to Certify Status Of Individuals for Withholding Under FATCA

Akerman LLP on

On September 11, 2012, the Internal Revenue Service (“IRS”) released a new draft version of Form W-8 BEN, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding (Individuals). This Form is used...more

Akerman LLP

IRS Issues Draft Withholding Forms Conforming To FATCA

Akerman LLP on

The Foreign Account Tax Compliance Act ("FATCA"), passed as part of the Hiring Incentives to Restore Employment (HIRE) Act enacted in March 2010, added a requirement which generally provides that a foreign financial...more

Foley Hoag LLP

First FBAR, Now FATCA: New Information Reporting Requirements for U.S. Taxpayers with Foreign Financial Assets

Foley Hoag LLP on

U.S. citizens, resident aliens and certain non-resident aliens who held “specified foreign financial assets” at any point during 2011 may be required to file IRS Form 8938 (Statement of Specified Foreign Financial Assets)...more

McDermott Will & Emery

Proposed Regulations Provide FATCA Compliance Guidance for Foreign Financial Institutions, Other Foreign Entities and U.S....

McDermott Will & Emery on

The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471–1474 of the Internal Revenue Code. The proposed regulations provide updated guidance on information...more

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